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Privacy policy

1.Introduction

1.1We are committed to safeguarding the privacy of [our website visitors, service
users].

1.2This policy applies where we are acting as a data controller with respect
to the personal data of [our website visitors and service users]; in other words,
where we determine the purposes and means of the processing of that personal data.

1.3We use cookies on our website. Insofar as those cookies are not strictly
necessary for the provision of [our website and services], we will ask you to consent
to our use of cookies when you first visit our website.

1.4Our website incorporates privacy controls which affect how we will process
your personal data. By using the privacy controls, you can [specify whether you
would like to receive direct marketing communications and limit the publication
of your information]. You can access the privacy controls via [URL].

1.5In this policy, "we", "us" and "our" refer to [data controller name].[
For more information about us, see Section 13.]

You must retain the above credit. Use of this document
without the credit is an infringement of copyright. However, you can purchase from
us an equivalent document that does not include the credit.

3.How we use your personal data

3.1In this Section 3 we have set out:

(a)the general categories of personal data that we may process;

(b)[in the case of personal data that we did not obtain directly from you, the
source and specific categories of that data];

(c)the purposes for which we may process personal data; and

(d)the legal bases of the processing.

3.2We may process [data about your use of our website and services] ("usage
data"). The usage data may include [your IP address, geographical location,
browser type and version, operating system, referral source, length of visit, page
views and website navigation paths, as well as information about the timing, frequency
and pattern of your service use]. The source of the usage data is [our analytics
tracking system]. This usage data may be processed [for the purposes of analysing
the use of the website and services]. The legal basis for this processing is [consent]
OR [our legitimate interests, namely [monitoring and improving our website and services]]
OR [[specify basis]].

3.3We may process [your account data] ("account data").[ The account
data may [include your name and email address].][ The source of the account data
is [you or your employer].] The account data may be processed [for the purposes
of operating our website, providing our services, ensuring the security of our website
and services, maintaining back-ups of our databases and communicating with you.]
The legal basis for this processing is [consent] OR [our legitimate interests, namely
[the proper administration of our website and business]] OR [the performance of
a contract between you and us and/or taking steps, at your request, to enter into
such a contract] OR [[specify basis]].

3.4We may process [your information included in your personal profile on our
website] ("profile data").[ The profile data may include [your name, address,
telephone number, email address, profile pictures, gender, date of birth, relationship
status, interests and hobbies, educational details and employment details].] The
profile data may be processed for [the purposes of enabling and monitoring your
use of our website and services]. The legal basis for this processing is [consent]
OR [our legitimate interests, namely [the proper administration of our website and
business]] OR [the performance of a contract between you and us and/or taking steps,
at you request, to enter into such a contract] OR [[specify basis]].

3.5We may process [your personal data that are provided in the course of the
use of our services] ("service data").[ The service data may include [specify
data].][ The source of the service data is [you or your employer].] The service
data may be processed [for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining back-ups
of our databases and communicating with you]. The legal basis for this processing
is [consent] OR [our legitimate interests, namely [the proper administration of
our website and business]] OR [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract] OR [[specify
basis]].

3.6We may process [information that you post for publication on our website
or through our services] ("publication data"). The publication data may be
processed [for the purposes of enabling such publication and administering our website
and services]. The legal basis for this processing is [consent] OR [our legitimate
interests, namely [the proper administration of our website and business]] OR [the
performance of a contract between you and us and/or taking steps, at your request,
to enter into such a contract] OR [[specify basis]].

3.7We may process [information contained in any enquiry you submit to us regarding
goods and/or services] ("enquiry data"). The enquiry data may be processed
[for the purposes of offering, marketing and selling relevant goods and/or services
to you]. The legal basis for this processing is [consent] OR [[specify basis]].

3.8We may process [information relating to our customer relationships, including
customer contact information] ("customer relationship data").[ The customer
relationship data may include [your name, your employer, your job title or role,
your contact details, and information contained in communications between us and
you or your employer].][ The source of the customer relationship data is [you or
your employer].] The customer relationship data may be processed [for the purposes
of managing our relationships with customers, communicating with customers, keeping
records of those communications and promoting our products and services to customers].
The legal basis for this processing is [consent] OR [our legitimate interests, namely
[the proper management of our customer relationships]] OR [[specify basis]].

3.9We may process [information relating to transactions, including purchases
of goods and services, that you enter into with us and/or through our website] ("transaction
data").[ The transaction data may include [your contact details, your card details
and the transaction details].] The transaction data may be processed [for the purpose
of supplying the purchased goods and services and keeping proper records of those
transactions]. The legal basis for this processing is [the performance of a contract
between you and us and/or taking steps, at your request, to enter into such a contract
and our legitimate interests, namely [the proper administration of our website and
business]] OR [[specify basis]].

3.10We may process [information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters] ("notification data"). The
notification data may be processed [for the purposes of sending you the relevant
notifications and/or newsletters]. The legal basis for this processing is [consent]
OR [the performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract] OR [[specify basis]].

3.11We may process [information contained in or relating to any communication
that you send to us] ("correspondence data"). The correspondence data may
include [the communication content and metadata associated with the communication].[
Our website will generate the metadata associated with communications made using
the website contact forms.] The correspondence data may be processed [for the purposes
of communicating with you and record-keeping]. The legal basis for this processing
is [our legitimate interests, namely [the proper administration of our website and
business and communications with users]] OR [[specify basis]].

3.12We may process [identify general category of data].[ This data may
include [list specific items of data].][ The source of this data is [identify
source].] This data may be processed for [specify purposes]. The legal
basis for this processing is [consent] OR [our legitimate interests, namely [specify
legitimate interests]] OR [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract] OR [[specify
basis]].

3.13We may process [any of your personal data identified in this policy] where
necessary for [the establishment, exercise or defence of legal claims, whether in
court proceedings or in an administrative or out-of-court procedure]. The legal
basis for this processing is our legitimate interests, namely [the protection and
assertion of our legal rights, your legal rights and the legal rights of others].

3.14We may process [any of your personal data identified in this policy] where
necessary for [the purposes of obtaining or maintaining insurance coverage, managing
risks, or obtaining professional advice]. The legal basis for this processing is
our legitimate interests, namely [the proper protection of our business against
risks].

3.15In addition to the specific purposes for which we may process your personal
data set out in this Section 3, we may also process [any of your personal data]
where such processing is necessary[ for compliance with a legal obligation to which
we are subject, or] in order to protect your vital interests or the vital interests
of another natural person.

3.16Please do not supply any other person's personal data to us, unless we prompt
you to do so.

4.Providing your personal data to others

4.1We may disclose [your personal data] to any member of our group of companies
(this means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal bases, set out
in this policy.[ Information about our group of companies can be found at [URL].]

4.2We may disclose [your personal data] to [our insurers and/or professional
advisers] insofar as reasonably necessary for the purposes of [obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice, or the establishment,
exercise or defence of legal claims, whether in court proceedings or in an administrative
or out-of-court procedure].

4.4Financial transactions relating to [our website and services] [are] OR [may
be] handled by our payment services providers, [identify PSPs]. We will share
transaction data with our payment services providers only to the extent necessary
for the purposes of [processing your payments, refunding such payments and dealing
with complaints and queries relating to such payments and refunds]. You can find
information about the payment services providers' privacy policies and practices
at [URLs].

4.5We may disclose [your enquiry data] to [one or more of those selected third
party suppliers of goods and services identified on our website] for the purpose
of [enabling them to contact you so that they can offer, market and sell to you
relevant goods and/or services].[ Each such third party will act as a data controller
in relation to the enquiry data that we supply to it; and upon contacting you, each
such third party will supply to you a copy of its own privacy policy, which will
govern that third party's use of your personal data.]

4.6In addition to the specific disclosures of personal data set out in this
Section 4, we may disclose your personal data where such disclosure is necessary
for compliance with a legal obligation to which we are subject, or in order to protect
your vital interests or the vital interests of another natural person.[ We may also
disclose your personal data where such disclosure is necessary for the establishment,
exercise or defence of legal claims, whether in court proceedings or in an administrative
or out-of-court procedure.]

5.International transfers of your personal data

5.1In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to [countries outside the European Economic
Area (EEA)].

5.2We[ and our other group companies] have [offices and facilities] in [specify
countries].[ The European Commission has made an "adequacy decision" with respect
to [the data protection laws of each of these countries].][ Transfers to [each of
these countries] will be protected by appropriate safeguards, namely [the use of
standard data protection clauses adopted or approved by the European Commission,
a copy of which can be obtained from [source]] OR [the use of binding corporate
rules, a copy of which you can obtain from [source]] OR [[specify appropriate
safeguards and means to obtain a copy]].]

5.3The hosting facilities for our website are situated in [specify countries].[
The European Commission has made an "adequacy decision" with respect to [the data
protection laws of each of these countries].][ Transfers to [each of these countries]
will be protected by appropriate safeguards, namely [the use of standard data protection
clauses adopted or approved by the European Commission, a copy of which you can
obtain from [source]] OR [[specify appropriate safeguards and means to
obtain a copy]].]

5.4[Specify category or categories of supplier or subcontractor] [is]
OR [are] situated in [specify countries].[ The European Commission has made
an "adequacy decision" with respect to [the data protection laws of each of these
countries].][ Transfers to [each of these countries] will be protected by appropriate
safeguards, namely [the use of standard data protection clauses adopted or approved
by the European Commission, a copy of which can be obtained from [source]]
OR [[specify appropriate safeguards and means to obtain a copy]].]

5.5You acknowledge that [personal data that you submit for publication through
our website or services] may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.

6.Retaining and deleting personal data

6.1This Section 6 sets out our data retention policies and procedure, which
are designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.

6.2Personal data that we process for any purpose or purposes shall not be kept
for longer than is necessary for that purpose or those purposes.

6.3We will retain your personal data as follows:

(a)[personal data category or categories] will be retained for a minimum
period of [period] following [date], and for a maximum period of
[period] following [date].

[additional list items]

6.4In some cases it is not possible for us to specify in advance the periods
for which your personal data will be retained. In such cases, we will determine
the period of retention based on the following criteria:

(a)the period of retention of [personal data category] will be determined
based on [specify criteria].

[additional list items]

6.5Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal obligation
to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.

7.Amendments

7.1We may update this policy from time to time by publishing a new version on
our website.

7.2You should check this page occasionally to ensure you are happy with any
changes to this policy.

7.3We [may] OR [will] notify you of [changes] OR [significant changes] to this
policy [by email or through the private messaging system on our website].

8.Your rights

8.1In this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws and
guidance from the regulatory authorities for a full explanation of these rights.

8.2Your principal rights under data protection law are:

(a)the right to access;

(b)the right to rectification;

(c)the right to erasure;

(d)the right to restrict processing;

(e)the right to object to processing;

(f)the right to data portability;

(g)the right to complain to a supervisory authority; and

(h)the right to withdraw consent.

8.3You have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain additional
information. That additional information includes details of the purposes of the
processing, the categories of personal data concerned and the recipients of the
personal data. Providing the rights and freedoms of others are not affected, we
will supply to you a copy of your personal data. The first copy will be provided
free of charge, but additional copies may be subject to a reasonable fee.[ You can
access [your personal data] by visiting [URL] when logged into our website.]

8.4You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any incomplete
personal data about you completed.

8.5In some circumstances you have the right to the erasure of your personal
data without undue delay. Those circumstances include: [the personal data are no
longer necessary in relation to the purposes for which they were collected or otherwise
processed; you withdraw consent to consent-based processing; you object to the processing
under certain rules of applicable data protection law; the processing is for direct
marketing purposes; and the personal data have been unlawfully processed]. However,
there are exclusions of the right to erasure. The general exclusions include where
processing is necessary: [for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment, exercise
or defence of legal claims].

8.6In some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the personal
data; processing is unlawful but you oppose erasure; we no longer need the personal
data for the purposes of our processing, but you require personal data for the establishment,
exercise or defence of legal claims; and you have objected to processing, pending
the verification of that objection. Where processing has been restricted on this
basis, we may continue to store your personal data. However, we will only otherwise
process it: with your consent; for the establishment, exercise or defence of legal
claims; for the protection of the rights of another natural or legal person; or
for reasons of important public interest.

8.7You have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal basis
for the processing is that the processing is necessary for: the performance of a
task carried out in the public interest or in the exercise of any official authority
vested in us; or the purposes of the legitimate interests pursued by us or by a
third party. If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the processing
which override your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.

8.8You have the right to object to our processing of your personal data for
direct marketing purposes (including profiling for direct marketing purposes). If
you make such an objection, we will cease to process your personal data for this
purpose.

8.9You have the right to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds relating
to your particular situation, unless the processing is necessary for the performance
of a task carried out for reasons of public interest.

8.10To the extent that the legal basis for our processing of your personal data
is:

(a)consent; or

(b)that the processing is necessary for the performance of a contract to which
you are party or in order to take steps at your request prior to entering into a
contract,

and such processing is carried out by automated means, you have the right
to receive your personal data from us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the rights
and freedoms of others.

8.11If you consider that our processing of your personal information infringes
data protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged infringement.

8.12To the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.

8.13You may exercise any of your rights in relation to your personal data [by
written notice to us] OR [by [methods]][, in addition to the other methods
specified in this Section 8].

9.About cookies

9.1A cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a page
from the server.

9.2Cookies may be either "persistent" cookies or "session" cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set expiry
date, unless deleted by the user before the expiry date; a session cookie, on the
other hand, will expire at the end of the user session, when the web browser is
closed.

9.3Cookies do not typically contain any information that personally identifies
a user, but personal information that we store about you may be linked to the information
stored in and obtained from cookies.

10.Cookies that we use

10.1We use cookies for the following purposes:

(a)[authentication - we use cookies [to identify you when you visit our website
and as you navigate our website][ (cookies used for this purpose are: [identify
cookies])]];

(b)[status - we use cookies [to help us to determine if you are logged into
our website][ (cookies used for this purpose are: [identify cookies])]];

(c)[personalisation - we use cookies [to store information about your preferences
and to personalise the website for you][ (cookies used for this purpose are:
[identify cookies])]];

(d)[security - we use cookies [as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login credentials,
and to protect our website and services generally][ (cookies used for this purpose
are: [identify cookies])]];

(e)[advertising - we use cookies [to help us to display advertisements that
will be relevant to you][ (cookies used for this purpose are: [identify cookies])]];

(f)[analysis - we use cookies [to help us to analyse the use and performance
of our website and services][ (cookies used for this purpose are: [identify cookies])]];
and

(g)[cookie consent - we use cookies [to store your preferences in relation to
the use of cookies more generally][ (cookies used for this purpose are: [identify
cookies])]].

[additional list items]

11.Cookies used by our service providers

11.1Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.

11.2We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information gathered
relating to our website is used to create reports about the use of our website.
Google's privacy policy is available at:
https://www.google.com/policies/privacy/.[
The relevant cookies are: [identify cookies].]

11.3[We publish Google AdSense interest-based advertisements on our website.
These are tailored by Google to reflect your interests. To determine your interests,
Google will track your behaviour on our website and on other websites across the
web using cookies.] OR [We publish Google AdSense advertisements on our website.
To determine your interests, Google will track your behaviour on our website and
on other websites across the web using cookies. This behaviour tracking allows Google
to tailor the advertisements that you see on other websites to reflect your interests
(but we do not publish interest-based advertisements on our website).] You can view,
delete or add interest categories associated with your browser by visiting:
https://adssettings.google.com.
You can also opt out of the AdSense partner network cookie using those settings
or using the Network Advertising Initiative's multi-cookie opt-out mechanism at:
http://optout.networkadvertising.org.
However, these opt-out mechanisms themselves use cookies, and if you clear the cookies
from your browser your opt-out will not be maintained. To ensure that an opt-out
is maintained in respect of a particular browser, you may wish to consider using
the Google browser plug-ins available at:
https://support.google.com/ads/answer/7395996.[
The relevant cookies are: [identify cookies].]

11.4We use [identify service provider] to [specify service]. This
service uses cookies for [specify purpose(s)]. You can view the privacy policy
of this service provider at [URL].[ The relevant cookies are: [identify
cookies].]

12.Managing cookies

12.1Most browsers allow you to refuse to accept cookies and to delete cookies.
The methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting cookies
via these links: